Privacy policy

1. Who we are and other important information

Who we are

Sona Technologies Ltd (Sona, we, our, or us) is the data controller and is responsible for your personal data collected through www.getsona.com (our website) and your interactions with us. This privacy policy applies to such personal data and explains how we collect it and use it. 

We have appointed an Information Security Officer who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact privacy@getsona.com. 

Changes to the privacy policy

We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

What this privacy policy doesn’t cover

Please note that if your employer uses our application then Sona is not a data controller of the personal data you, or your employer, inputs into the application. Your employer remains data controller of this personal data and you should refer to your employer’s employee privacy policy for further information. 

Our website is not intended for children and we do not knowingly collect data relating to children.

Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can, directly or indirectly, be identified. It does not include data where the identity has been irreversibly removed (anonymous data).

We may collect, use, store and transfer different kinds of personal information about you. The types of personal information we collect depends on the nature of our relationship with you. The kinds of personal information we collect can be grouped together as follows:

• Identity and contact data. Such as your name, username or similar identifier, phone number, email address, title, date of birth and gender. 
• Technical data. Such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website (some of this data may be anonymised).
• Profile data. Such as your interests, preferences, feedback and survey responses.
• Information from discussions on webinars (including video imagery and sound) or similar public forums. Any information that you disclose in these locations may be recorded, archived, and republished. 
• Usage data. Such as information about how you use our website and services.
• Marketing data. Including your preferences in receiving marketing from us and your communication preferences.
• Information from third-party sources. We may receive information about you from publicly and commercially available sources (always in compliance with the law) which we may combine with other information we receive from or about you. We also may receive information about you from third-party social networking services when you choose to connect with those services. We may notify you when we receive information about you from them and the purposes for which we intend to use that information.
• Other information. You may choose to provide us with information when you contact us, respond to surveys, fill in forms, or use other features of our website or services. We may keep a record of that information and/or correspondence. 

We may also put your personal information into aggregated and anonymised form. Once anonymised, that data is no longer classed as personal information. 

We do not, via the website or our interactions with you, collect any sensitive personal information about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

If you fail to provide personal information 

Where we need to collect personal information in order to provide a service, for example invite you to a webinar or use a feature of the website, and you fail to provide that data when requested, we may not be able to provide that service to you.

How is your personal information collected?

We use different methods to collect information from and about you including through:

• Direct interactions. You may give us your data by filling in forms on our website or by corresponding with us by post, phone, email or otherwise. This includes personal information you provide when:
  • you interact with us on our website;
  • you subscribe to our mailing list, newsletter, webinars or any publications;
  • you request marketing to be sent to you;
  • you enter a competition, promotion or survey; or
  • you give us feedback or otherwise contact us.
• Attendance at any events that we run. This includes webinars, where video imagery and sound may be recorded, and in-person events where you might, for example, fill out contact forms or similar.
• Automated technologies or interactions. As you interact with our website, we will automatically collect technical data about your equipment, browsing actions and patterns. We collect this information by using cookies and other similar technologies. Please see our Cookie Policy for further details.
• Third parties or publicly available sources. We will receive personal information about you from various third parties and public sources as set out below:
• analytics providers such as Google based outside the UK; and
• Cognism, our business to business data provider.

3. How we use your personal information

We will only collect, use and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

• you have provided your consent to us using the personal information;
• our use of your personal information is in our legitimate interest as a commercial organisation;
• our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and
• our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have. 

We have set out below a description of all the ways we plan to use your personal information, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Marketing

You will receive marketing communications from us (usually by email or by phone, including messaging such as WhatsApp) if you have requested information from us, attended a tradeshow and provided us with your email address and/or phone number, signed up to our mailing list, newsletter or attended any webinar or other event we host and you have not opted out of receiving that marketing.

Please only provide your contact details to us when acting in your professional or business capacity. 

We will provide you with an opportunity to opt-out of our marketing on each of our marketing communications. However, we may continue to send non-marketing service-related communications (for example, communications regarding updates to this privacy policy). If you do opt-out of marketing communications, we will retain your telephone number and/or email address on a ‘do not contact for marketing purposes’ list, to make sure we avoid sending marketing communications to you in the future.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use and how to manage them, please see our cookie policy.

4. Who do we share your personal information with?

We may share your personal information as set out below for the purposes set out in the table above: 

• IT service providers, providing system administration, hosting and support services. 
• Third party analytics companies and service providers that facilitate our marketing activities (such as HubSpot).
• Within Sona and its group companies where such disclosure is necessary for the stated purposes.
• Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
• Law enforcement/government agencies or regulators.
• Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal information in the same way as set out in this privacy policy. 
• We may also provide your personal information to social media companies such as Facebook, Instagram and LinkedIn for the purposes of ensuring that you receive adverts from us that are relevant to your browsing or to target individuals with similar interests to you, with our products and services.

5. International transfers

Some of the third-party service providers we use to deliver the website and its features are based outside of the UK. Their processing of your personal data will therefore involve a transfer of data outside the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data (for example the countries of the European Economic Area are deemed to provide adequate protection).
• Where we use certain service providers outside of the UK, we may use specific contracts approved for use in the UK, as well as additional technical safeguards and measures if appropriate, which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

6. Data security

We have implemented and maintain appropriate security measures to reduce the risk of your personal information being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Where we share personal information with our staff, they will only process your personal information on our instructions and they are subject to a duty of confidentiality. Similarly, we will only share your personal information with third parties where that third party is under contractual obligations to ensure you personal information is protected in compliance with the law.

7. Data retention

How long will you use my personal information for?

We will only retain your personal information for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of providing our services, to resolve disputes, to establish legal defences, to conduct audits, to pursue legitimate business purposes, to enforce our agreements and in satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal information for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

8. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal information. In summary, these rights are as follows:

• Request access to your personal information. This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it.
• Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
• Request erasure of your personal information. This enables you to ask us to delete or remove personal information in certain circumstances. 
• Object to processing of your personal information where we are relying on a legitimate interest. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
• Object to processing your personal information for direct marketing purposes. 
• Request restriction of processing of your personal information in certain circumstances.
  
• Request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
• Withdraw consent at any time where we are relying on consent to process your personal information. 

If you wish to exercise any of the rights set out above, please contact us using the details provided at the top of this policy. 

You also have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please try to contact us in the first instance.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.